Extra-EU exports of machinery and vehicles reached €1,013 billion in 2024, and almost none of it crossed a border without a manual attached. If you build machinery for European markets, one of those manuals is about to become a bigger part of your compliance work. Regulation (EU) 2023/1230, the new Machinery Regulation, applies from 20 January 2027 with no phase-in period. It changes what your translated documentation is for. A regulatory affairs lead used to treat the translated manual as a secondary version sitting beside an authoritative original.
From January 2027, the version a French or Finnish operator reads is the legally required instructions in that market, held to the same standard as the source. This guide walks through what you translate, into which languages, how the new digital rules work, and how a technical documentation team keeps a multilingual manual set compliant without the cost running away.
TL;DR
| • The EU Machinery Regulation (Regulation (EU) 2023/1230) replaces the Machinery Directive and applies from 20 January 2027 with no phase-in. • Manufacturers must supply the instructions for use, assembly instructions, safety information and the EU declaration of conformity in the official language(s) of every member state where the machinery is placed on the market. • Each member state sets its own language rule, so a company selling across the EU and EEA manages a matrix of required languages rather than one default. • For the first time, instructions may be supplied digitally, provided users can print, download and save them and the files stay available online for the machine’s expected lifetime and at least 10 years, with a free paper copy on request. • Because the translated instructions now carry full legal weight, translation quality becomes a compliance question, best handled with an ISO 17100 workflow, managed terminology and in-country review. • Manufacturers with large product families keep this affordable by authoring in structured content and connecting their systems to the translation workflow. |
What the EU Machinery Regulation requires you to translate
Under Regulation (EU) 2023/1230, manufacturers must provide the instructions for use, assembly instructions, safety information and the EU declaration of conformity in the official language(s) of every member state where the machinery is placed on the market. The technical file goes to the authority or the Notified Body, which often accepts English as a working language, but everything an operator or installer reads follows the market’s language rule. A structured approach to technical translation is what keeps that scope under control across a product range.
The move from a directive to a regulation matters for how uniform the rules are. A directive is written into national law by each member state, which leaves room for local variation. A regulation applies directly and the same way everywhere, so the main area national authorities still control is language.
| Aspect | Machinery Directive 2006/42/EC | Machinery Regulation (EU) 2023/1230 |
|---|---|---|
| Legal form | Transposed into national law by each member state | Applies directly in every member state |
| Instructions format | Paper expected | Digital permitted under conditions, paper on request |
| Translated instructions | A translation beside the original | The instructions in the market language are the required instructions |
| Cybersecurity | Not addressed as such | Documentation expectations introduced |
| AI and autonomous machinery | Not covered | Addressed |
| Status | In force since 2009 | Applies from 20 January 2027 |
From directive to regulation: what actually changed
Three changes touch your documentation directly. Manufacturers may now deliver instructions digitally, they have to document how the machine handles cybersecurity risks that could affect safety, and they face new provisions for machinery that uses artificial intelligence or behaves autonomously. Each of these adds content that needs translating, and the AI and cybersecurity material tends to be the most terminology-heavy part of the manual.
The documents in scope for translation
- Instructions for use, including installation, operation, maintenance and decommissioning.
- Assembly instructions for partly completed machinery, plus the EU declaration of incorporation.
- Safety information and warnings, whether printed, on-product or on-screen.
- The EU declaration of conformity, which accompanies the machinery.
Which languages, in which markets
Instructions for use must appear in the official language(s) of each member state where you place the machinery, and each market sets that rule nationally. Sell a packaging line into Germany, France and Finland and you are working in German, French, and both Finnish and Swedish, because Finland recognises two official languages. Most manufacturers keep this straight with a language matrix that maps every target market to its required language or languages, then treat that matrix as a controlled document with a version number and a review date.
The table below maps EU and EEA markets to the official language(s) an operator-facing manual is expected in. Treat it as a working reference and confirm each market against its national implementing measures before you lock a project, since a few states apply specific conditions for professional-use machinery.
| Market | Required language(s) for instructions |
|---|---|
| Austria | German |
| Belgium | Dutch, French and German by region |
| Bulgaria | Bulgarian |
| Croatia | Croatian |
| Cyprus | Greek |
| Czechia | Czech |
| Denmark | Danish |
| Estonia | Estonian |
| Finland | Finnish and Swedish |
| France | French |
| Germany | German |
| Greece | Greek |
| Hungary | Hungarian |
| Ireland | English |
| Italy | Italian |
| Latvia | Latvian |
| Lithuania | Lithuanian |
| Luxembourg | French and German |
| Malta | Maltese or English |
| Netherlands | Dutch |
| Poland | Polish |
| Portugal | Portuguese |
| Romania | Romanian |
| Slovakia | Slovak |
| Slovenia | Slovenian |
| Spain | Spanish |
| Sweden | Swedish |
| Norway (EEA) | Norwegian |
| Iceland (EEA) | Icelandic |
| Liechtenstein (EEA) | German |
Based on the official language(s) of each market. National measures can add conditions, so verify before committing a language set.
You translate into markets, not all of Europe
The European Union has 24 official languages, and a common worry is that machinery has to ship in all of them. It does not. You translate into the languages of the markets you actually sell into. A manufacturer active in six countries manages six to eight languages, not twenty-four, which is why the market list drives the budget, not the map of Europe.
Where English is, and is not, accepted
English works as the language of the technical file for many Notified Bodies, and it is the operator language in Ireland and Malta. Outside those cases, English is not a safe default for user-facing instructions. If a supplier or an internal team assumes English will cover a professional-use exemption in a given market, treat that as a claim to verify with the competent authority, in writing, before you rely on it.
| Germany in practice. Germany is the largest market for many of the manufacturers and e-commerce brands we work with, and its implementing act, the Maschinen-Durchführungsgesetz (MaschinenDG), requires the instructions for use, the assembly instructions and the EU declaration of conformity to be drawn up in German. There is no professional-user shortcut around German here, so it anchors most language matrices that include the DACH region. |
Digital instructions: what “provided digitally” actually requires
You can now supply the instructions for use in a digital format, and this is one of the biggest changes in the Regulation. The permission comes with conditions. Users have to be able to print, download and save the instructions, you have to show on the machinery how to reach them, and the files have to stay online for the machine’s expected lifetime and at least 10 years after it goes on the market. Anyone who asks for a paper copy at the point of purchase gets one free of charge, within one month. For machinery that a non-professional might use, the safety information needed to commission and run it safely still ships on paper. You can connect your content systems with SmartConnect so the online versions in every language update together when the source changes.
| Condition | What it means for you |
|---|---|
| Access shown on the machine | Print on the machinery or its paper companion how to reach the digital instructions. |
| Print, download, save | The format has to let the user print, download and save the file. |
| Online availability | Keep the instructions online for the machine’s expected lifetime and at least 10 years after it is placed on the market. |
| Paper on request | Supply a paper copy free of charge on request at purchase, within one month. |
| Safety information on paper | For machinery non-professionals may use, provide the safety information for commissioning and safe use on paper. |
What digital delivery changes for translation and versioning
The 10-year availability rule turns version control into a compliance task. If you update a hazard warning in the source manual, every language version online has to move with it, and you need to show which version applied when a given machine shipped. Teams that manage this well keep the source and its translations in one connected workflow, so a change to the German file is not left behind while the French and Polish files sit at an older revision.
Why translated instructions now carry full legal weight
From January 2027, the instructions an operator reads in their own language are the legally required instructions, not a convenience copy. A mistranslated warning or an ambiguous maintenance step is a compliance gap and a liability exposure in that market, and market surveillance authorities can act on the documentation as it stands in each language. This is why regulatory leads are moving translation quality from a procurement afterthought to a controlled process, usually built on ISO 17100 for translation and revision and, where machine translation is post-edited, ISO 18587.
Consistency across a product family is part of that quality picture. A reviewer who checks one manual in isolation can still miss a term that drifts between the manual, the on-product label and the interface. Managed terminology management keeps safety-critical terms fixed across all three, so a component is called the same thing wherever an operator meets it.
| A worked example. A manufacturer we worked with ran a final in-country review on a Danish manual before launch. The reviewer flagged that a warning about a moving guard had been softened in translation, so it read as advisory rather than mandatory. The fix took an afternoon. Left in place, it would have shipped on every unit and become the authoritative Danish instruction for that hazard. |
What “clear and comprehensible” means for translation quality
The Regulation expects instructions to be clear and comprehensible, and comprehensibility is judged in the target language by the person using the machine. A source-language sign-off cannot confirm that a Polish operator will read a step the way you intend. An in-market specialist reviewing the translated instructions is the control that actually tests this, which is why in-country review sits in the workflow rather than at the edge of it.
How structured content and terminology keep multilingual manuals compliant and affordable
Manufacturers with large product families keep multilingual manuals both compliant and affordable by writing in structured content, governing their terminology, and connecting the systems that hold the content to the translation workflow. This is the people, process, and technology story in practice. In-market specialists handle the review, a repeatable process governs how updates move, and connected tools carry the content so nobody is copy-pasting between systems. The pieces below fit together into one loop.
| Step | What happens |
|---|---|
| Source change | A manual section or an interface string is updated in your CMS or PIM. |
| Connector | SmartConnect moves the changed content to AdHoc without a manual export. |
| Memory and termbase | Repeated content and approved terms are applied automatically. |
| In-country review | An in-market specialist checks comprehensibility in the target language. |
| Final-layout check | Reviewers check the manual in its finished layout in SmartEdit. |
| Publish | The updated instructions return to your systems and stay available online. |
Structured authoring and translation memory
Component authoring in DITA, XML or S1000D means a shared warning or a common maintenance procedure is written once and reused across every product that needs it. Paired with translation memory, that shared content is translated once and reused too, so a fifty-manual range does not become fifty separate translation jobs each time a term changes.
Terminology governance across product families
A maintained termbase is where you decide, once, what each safety-critical component and action is called in every language, then hold every manual and interface to it. When an auditor or an operator compares the label, the manual and the screen, the words match.
Connecting your CMS or PIM to the translation workflow
SmartConnect links the systems that hold your content to AdHoc, so updates flow automatically and reviewers work in the final layout through SmartEdit rather than marking up PDFs. For a team shipping frequent revisions across a language matrix, that connection is what keeps the online instructions current without a person shuttling files by hand.
What the Machinery Regulation means for robotics companies
Robots are machinery under Regulation (EU) 2023/1230, so if you build autonomous mobile robots or collaborative robots for European markets, the same language and instruction duties apply to you. The wrinkle for robotics is that the content an operator meets goes beyond the printed manual. Much of it sits on the screen and in the error messages the machine shows when something goes wrong, and those are just as user-facing.
Robots as machinery: what falls in scope
An autonomous mobile robot moving stock around a warehouse and a cobot working next to a line operator both meet the definition of machinery. Their instructions for use, safety information and declaration of conformity carry the same per-market language requirement as any other machine, and the Regulation’s provisions for autonomous behaviour mean the safety documentation tends to be longer and more technical.
Interface strings, HMIs and software content
The text on a robot’s human-machine interface, its warning prompts and its error messages guide how an operator responds in the moment, which puts them under the same comprehensibility expectation as the printed instructions. Treating interface strings as part of the same terminology and review process as the manual keeps a warning worded the same way on the screen and on the page, instead of a translator meeting the phrase twice and rendering it two ways.
Machinery Regulation translation vendor checklist
A supplier ready for the Machinery Regulation holds the right certifications, reviews in the target market, manages terminology, handles structured content and connectors, and can show you a documented QA cycle with realistic per-language lead times. If your current supplier cannot answer the rows below with evidence rather than assurances, that gap is worth closing well before the 2027 deadline. Score a prospective partner against it.
| Capability | Why it matters under the Regulation | Evidence to ask for |
|---|---|---|
| ISO 17100 certification | A controlled translation and revision process for content that now carries legal weight | Current certificate, scope and reviser qualifications |
| ISO 18587 for post-edited MT | A defined standard where machine translation is post-edited | Certificate and a written post-editing policy |
| In-country review | Comprehensibility is judged in the target market | Named in-market reviewers and review records |
| Terminology management | Consistent safety-critical terms across manuals, labels and interfaces | Termbase samples and a governance process |
| Structured content and connectors | Efficient updates across a product family and its languages | CMS or PIM integration examples and DITA/XML handling |
| Documented QA and lead times | Predictable delivery across a language matrix before the deadline | A sample QA cycle and per-language lead-time figures |
A portal like SmartDesk gives you the project visibility and reporting to check that evidence on live work, rather than taking it on trust at the pitch.
Frequently asked questions
When does the EU Machinery Regulation apply?
Regulation (EU) 2023/1230 applies from 20 January 2027, with no phase-in period. Machinery placed on the EU market from that date must meet the new requirements, including the language and instruction provisions.
Which languages must machinery instructions be translated into?
The instructions for use must be provided in the official language(s) of each member state where the machinery is placed on the market. Manufacturers selling across the EU and EEA usually work from a language matrix rather than a single default, and each market sets its own rule.
Can instructions for use be provided digitally under the new regulation?
Yes. Manufacturers may supply the instructions in a digital format, provided users can print, download and save them and the instructions stay available online for the machine’s expected lifetime and at least 10 years. A paper copy must be provided free of charge on request, within one month. For machinery that non-professionals may use, the safety information needed for commissioning and safe use is still supplied on paper.
Does the Machinery Regulation apply to robots?
Yes. Robots, including autonomous mobile machinery and collaborative robots, fall within the definition of machinery under Regulation (EU) 2023/1230. Their instructions, safety information and, where relevant, on-device interface text are in scope for translation.
Do UK manufacturers need to comply when selling into the EU?
Yes. A UK manufacturer placing machinery on the EU market must meet the Machinery Regulation, including its translation and language requirements, regardless of where the company is based.
What is the difference between the Machinery Directive and the Machinery Regulation?
The Machinery Directive (2006/42/EC) was transposed into national law by each member state, which allowed variation. The Machinery Regulation (2023/1230) applies directly across the EU, permits digital instructions, adds cybersecurity documentation, and addresses AI and autonomous machinery. It applies from 20 January 2027.
Book a workflow review
With 20 January 2027 in view, the practical next step is to check whether your current documentation workflow can carry the new legal weight across every market you sell into. If the vendor checklist above raised more questions than answers, book a workflow review or speak with our localisation team, and we will map your language matrix, your documents in scope and the connections that keep them current.
Sources
EUR-Lex, Regulation (EU) 2023/1230 of the European Parliament and of the Council on machinery. Application date 20 January 2027. https://eur-lex.europa.eu/eli/reg/2023/1230/oj/eng
Eurostat, Exports of machinery and vehicles reached €1,013 billion, news article, 8 September 2025. https://ec.europa.eu/eurostat/web/products-eurostat-news/w/ddn-20250908-1
Germany, Maschinen-Durchführungsgesetz (MaschinenDG), national implementing act for Regulation (EU) 2023/1230.
European Union, official languages of the EU. https://european-union.europa.eu/principles-countries-history/languages_en
ISO 17100:2015, Translation services: requirements for translation services.
ISO 18587:2017, Translation services: post-editing of machine translation output, requirements.